DATE: | January 18, 2008 |
SUBJECT: | The Notice of Missed Interview When a Household Has Not Submitted an Application for Recertification |
TO: | All Regional Directors Food Stamp Program |
We are writing to clarify the policy about sending Notices of Missed Interviews in conjunction with recertifications.
Whenever a state agency schedules a recertification interview and the household misses the interview the state agency must send a Notice of Missed Interview.
The Nov. 21, 2000, final rule on Noncitizen, Eligibility, and Certification Provisions of PL 104-193 (the NECP rule) requires a state agency to send a Notice of Missed Interview when a household misses a previously scheduled interview.
A subsequent question and answer about that requirement says:
Question N-4
State agency sends a Notice of Expiration, a blank re-application form, and the date and time of a scheduled appointment. The household never contacts the state agency. Must the state agency send a Notice of Missed Interview?
Answer N-4
No. The household has not re-applied, so it is not entitled to a Notice of Missed Interview.
At the time, state agencies almost always required a household to submit an application for recertification before the state agency would schedule an interview. If a household did not file the recertification form, it was logical to conclude that the household did not want to continue its participation in the program. Thus, there was no reason to send a Notice of Missed Interview.
Since then, many state agencies have adopted streamlined procedures, in accordance with 7 CFR 273.14(a)(2), for households to use when they reapply. One of these, an interactive application, combines the act of re-applying with the interview. Typically, the household receives an appointment or is instructed to make an appointment for the recertification interview. During the scheduled interview, an eligibility worker asks questions, the household responds, and the worker enters the responses into a computer. Those entries constitute the re-application. In such a system, it is not meaningful to say that a household is not entitled to a Notice of Missed Interview simply because the household has not previously submitted an application for recertification. Therefore, a Notice of Missed Interview is appropriate when the household misses that scheduled appointment.
Even if the state agency employs the procedure illustrated in Question/Answer N-4 and the household fails to submit an application for recertification, it should consider another contact with the household to provide a final reminder that benefits will end unless the household takes the required actions. This may result in more eligible households recertifying and not needing to file a new application after termination.
Food and Nutrition Service (FNS) regional offices should direct any comments or questions about this policy to their liaisons in the Certification Policy Branch. State agencies should direct their comments and questions to their FNS regional offices.
Arthur T. Foley
Director
Program Development Division